14 Cost Effective Actions to Cut Central London Air Pollution
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PAR HILL RESEARCH LTD Science,
Environment &
Policy Research
Email: iarlakd@gmail.com
Tel: +44 7739 804 892
14 Cost Effective Actions to
Cut Central London Air Pollution
I. Kilbane-Dawe, Par Hill Research Ltd,
6 Salcombe Lodge, 1 Lissenden Gardens, London NW5 1LZ, United Kingdom.
Email: iarlakd@gmail.com Tel: +44 7739 804 892
Guidance prepared for
Iarla Kilbane-Dawe, Par Ms Kyri Eleftheriou-Vaus,
Hill Research Royal
Ltd, 6 Salcombe Lodge, Borough
1 Lissenden of London
Gardens, Kensington
NW5 1LZ,&United
Chelsea, onEmail:
Kingdom. behalf of the Central
iarlakd@gmail.com London
Tel: +44 7739 804Air
892Quality Cluster Group.
Par Hill Research Ltd, Science, Environment & Policy Research 14 Cost Effective Actions to Cut Central London Air Pollution Guidance prepared for Ms Kyri Eleftheriou-Vaus at the Royal Borough of Kensington & Chelsea, on behalf of the Central London Air Quality Cluster Group of Authorities comprising City of London, City of Westminster, London Borough of Camden, London Borough of Hackney, London Borough of Islington, London Borough of Lambeth, London Borough of Southwark and the Royal Borough of Kensington & Chelsea. Release 1, 20 June 2012. Release 2, 31.7.2012. © 2012 I. Kilbane-Dawe, Par Hill Research Ltd. The content may be distributed freely without the permission of the copyright holder in electronic or other format, so long as the source and copyright are acknowledged. All photos © 2012 I. Kilbane-Dawe unless otherwise stated. Par Hill Research Ltd, Company No. 7951099, VAT Reg No. 128939572, Registered office: 11 Hove Business Centre, Fonthill Rd, Hove BN3 6HA UK. Registered in England & Wales 2 - 14 Cost Effective Actions To Cut Air Pollution In Central London
Par Hill Research Ltd, Science, Environment & Policy Research
Vertical roof exhausts on buses are low cost and have been demonstrated to
Executive Summary
Executive Summary cut emissions impacts by about 90% in the USA and Australia and should be
implemented in London. Many Euro IV bus engines can be cheaply
Great strides have been made in cutting Central London air pollution in the last
reprogrammed to have Euro V emissions. By doing so, a sufficient fleet of Euro
60 years and London’s air is now the cleanest it has been since the 1800s. But
V buses can be assembled for all Central London routes to be delivered using
significant local pollution remains and leads to the early deaths of hundreds of
only Euro V buses or better. Diesel Particle Filters can eliminate 99% of PM
Londoners each year as well as breaches of UK and EU law, so continuing
exhaust from Euro III taxis at low cost and these should be required. All three
action is warranted. Having dealt with the smoke stacks and filthy vehicle
of these measures can be implemented cost effectively using an LEZ.
motors of the past more difficult, potentially expensive and novel actions are
now needed. To meet this need some 400 documents were examined across The GLA’s proposal to require new buildings to be air quality neutral is essential
94 possible actions drawing from examples on three continents and compared to reducing building pollution. Often CSH or BREEAM Level 4 compliance
for their costs and benefits. Fourteen actions were found that are expected to delivers this, or for more intensive developments Passivhaus compliance. Old
be cost effective in London, with Benefit-to-Cost Ratios in the range 22 to 2. gas boilers should be replaced by ultra-low NOx boilers when replaced instead
of Class 4 or 5, reducing emissions by 40%-60% more at no extra cost.
Some cost effective actions can be delivered immediately, although they are
Energy efficiency should be accelerated and uptake of Warm Front and other
small in total air pollution impacts. They are also highly visible symbols of
schemes should be encouraged by councils. In all cases wood fuels should be
councils commitment to improve air quality. They are:
avoided.
• business engagement programmes, such as CityAir;
Cycling is very cost-effective, saving typical commuters £740pa. TfL research
• expansion of car clubs, which raise revenue, reduce car use and pollution; shows that 61% of Central London journeys can easily be cycled. Financial
and air pollution evidence strongly supports cycling becoming the top priority
• ecodriving training for taxi drivers, saving money and pollution; road transport mode in Central London, with target modal share of 10%-15%
being achievable. To deliver this, London’s seven cycle networks need to be
• iuse of competitively priced zero emission services where they exist;
harmonised, integrated and re-signed. Cycle lanes should eventually be
• idling enforcement at large taxi ranks to get driver to switch off engines; converted to tracks when pilot schemes to trial low costs designs for cycle
tracks are complete. Cycle hire is the most cost-effective way to increase
• if an exceedence is forecast, advertising to discourage polluting vehicles
cycling, and should be expanded across Inner London once funding permits.
across London and CMA application on the most polluted roads.
Extensive vegetation can substantially reduce air pollution in its immediate
These actions would reduce emissions in Central London by about 2%pa, and
vicinity. Evidence suggests lower cost planting methods exist than those
in-day by 7%-9% for advertising and 14% using CMA. Larger reductions can
currently used and these should be investigated. Evidence suggests that a
be achieved using the following actions, which would save £248Mpa and
Crossrail station at Kensal Rise is likely to reduce local air pollution.
reduce air pollution impacts by 4,768t.pa of NOx and 81t.pa of PM.
3 - 14 Cost Effective Actions To Cut Air Pollution In Central London
Par Hill Research Ltd, Science, Environment & Policy Research Dedication The best ideas contained herein stemmed from conversations with my friend and colleague Gwyn Jones MSc (1969-2011), a formidable scientist, a proud Welshman and a great believer in action on air pollution rather than words. Some of his proudest moments off the rugby pitch were when he helped such action to happen in his adopted home of Oxford. I. Kilbane-Dawe, June 2012 4 - 14 Cost Effective Actions To Cut Air Pollution In Central London
Par Hill Research Ltd, Science, Environment & Policy Research
Crossrail At Kensal Green ....................................................82
Table of Contents Asphalt Concrete Types ........................................................83
INTRODUCTION 7 Auxiliary Power Units for Diesel Locomotives ...................84
Low emissions RCVs ............................................................86
How To Use This Document .................................................8
Street sweeping and washing ..............................................87
LARGE IMPACT ACTIONS 15
Green Walls and Trees ..........................................................88
Three Viable Low Emission Zone Options ..........................16
Cycling ....................................................................................25
REFERENCES 91
Buildings and Air Pollution ...................................................38
EPISODE REDUCTION ACTIONS 59
Campaign Days for Episode Management .........................60
Dust Suppressants ................................................................67
QUICK WIN ACTIONS 69
Business engagement: Walk to the Client example ...........70
Car Clubs ...............................................................................71
Ecodriving training programmes .........................................75
Zero Emission services .........................................................79
Idling enforcement using PCN Code 63 ..............................80
OTHER INFORMATION 81
5 - 14 Cost Effective Actions To Cut Air Pollution In Central London
Par Hill Research Ltd, Science, Environment & Policy Research
Lisa Fasano, Bay Area Air Quality Management District
Acknowledgements Marcus Seaman, Liftshare Ltd
The Author is particularly grateful to the following experts for their generous
Mark Laurence, Biotecture
contributions and comments, and to many others:
Mateo Jaramillo, Tesla Motors
Brian Deegan, LB Camden
Matthew Linnecar, Gnewt Cargo
Charles Buckingham, TfL
Matthew Wells, City of New York Parks Dept
Chris Gaze, Buildings Research Establishment
Mike LeRoy
Chris Thomas, Environment Dept, New South Wales
Nigel Griffiths
Christina Andersen, Crossrail
Oliver Stutter, LB Southwark
Damian Breen, Bay Area Air Quality Management District
Paul Clift, LB Islington
David Carruthers, CERC
Poppy Lyle, LB Camden
David Carslaw, Kings College London
Rob Mackenzie, U. Birmingham
Elliot Trehearne, GLA
Robert Cottrell, PWC
Fiona Jackson
Roger Bluett, Environment Dept, New South Wales
Florinda Boschetti, European Cyclist Federation
Ruth Calderwoord, City of London
Gerd van Aaken, HJS UK Representation
Saleem Patel, LB Lambeth
Grant Klein, PWC
Simon Cross, Buildings Research Establishment
Harold Garner, LB Camden
Simon Jarrett, Chiltern Railways
Inga Mills, Health Protection Agency
Tim Starley-Grainger, City of Westminster
Jan Helmsley, Jean Lefevre (UK) Ltd
Mike Collup, National Travel Survey, DfT
John Collier, Greater Manchester Fire Service
Matt Dickinson, Buildings Research Establishment
Kate Johnson, LB Southwark
With special thanks to Guy Denington at RB Kensington & Chelsea for his very
Kyri Eleftheriou-Vaus, RB Kensington & Chelsea useful editorial comments.
6 - 14 Cost Effective Actions To Cut Air Pollution In Central London
Par Hill Research Ltd, Science, Environment & Policy Research
INTRODUCTION
& INSTRUCTIONS FOR USE
INTRODUCTION THE NATURE OF THE PROBLEM
THE STRATEGIC APPROACH
RECOMMENDED SOLUTIONS
TABLE OF COST EFFECTIVE MEASURES
7 - 14 Cost Effective Actions To Cut Air Pollution In Central London
Par Hill Research Ltd, Science, Environment & Policy Research
Introduction How To Use This Document
Introduction
Concerns about London’s air pollution have existed for hundreds of years - the The document can be used both to inform a general audience on air quality
earliest known air pollution regulation in London was a ban on coal fires by and what to do about it (Executive Summary and Chapter 1), to help design
Edward I in the 1300s. The Great Smog of 1952 killed 5,000 Londoners and detailed plans on major measures to reduce air pollution over time or in-day
prompted decades of strong action, reinforced by scientific evidence on the using the Frameworks in Chapters 2 and 3, or to quickly assemble a set of
effects of pollution on cancer, heart disease, acid rain and so on. The result is cost-effective measures that are very visible and capable of delivering small but
that London’s air pollution - while still higher than is recommended or legally effective pollution and cost reductions, as described in Chapter 4.
permitted in many areas - is certainly the cleanest its been in 100 years, and
The document contains a wealth of supporting evidence, with over 70 of the
more likely the cleanest its been since the beginning of the industrial revolution.
referenced documents included in an accompanying database. For each
Cleaning London’s air further means gradually eliminating the remaining intense action, both high impact, acute episode and quick win, a short summary with
sources of pollution - like taxis, buses and old gas boilers - in a cost effective key data is provided at the beginning, including socio-economic and cost-
way, that doesn’t ask the impossible of the individuals and organisations who benefit analysis summary figure that can be used to support discussion and
have invested in them. It also means ensuring that new sources of air pollution policy development. These data are also presented as a summary table (page
- such as biomass heating fuel - are nipped in the bud before damage is done. 12) which can be ranked by BCR, cost etc in order that measures can be
understood and ordered according to the local priorities of the Authority in
This report identifies fourteen such actions, based not on the work of the
question.
author, but that of the hundreds of experts who wrote the 400 studies on
which it is based. It is the product of the contribution of many transport, In addition to the References Database, a Document Compendium is available
buildings and environment experts, in councils, the GLA, TfL, Defra, in private which includes about 400 documents, files and databases which have been
firms and from other cities, who freely gave their expertise during meetings to used or referred to during the study, in unsorted format.
discuss practical ideas and options for air pollution reduction.
8 - 14 Cost Effective Actions To Cut Air Pollution In Central London
Par Hill Research Ltd, Science, Environment & Policy Research
The Nature Of Central London’s Air Pollution Problem
Nature Of The Problem
London is the greatest city in the World and Central London is her beating
heart. A major engine of World growth and employment, Central London has
two million residents and employs two million people of whom 95% commute
in [TfL, 2010a]. It generates GDP of £120Bn [Eurostat, 2009], more than
Kuwait, Qatar and 140 other countries. Travelling in by bus, train, car, and taxi
each day we cause 9 tonnes of toxic nitrogen dioxide (NO2) and 560kg of
toxic particulate air pollution (PM) to be emitted [LAEI, 2008], as well as
thousands of tonnes of CO2. Heating our homes and workplaces releases
3,000t of NO2, 30t of PM, and megatonnes of CO2 each year [ibid]. More air
pollution comes from aircraft, rail and road services for business and leisure
travellers, and yet more is blown in from upwind power stations and shipping.
London’s buildings and airports and the ships and power stations upwind
create a background miasma of elevated PM and NO2, while the crowded
roads and dense buildings of the Centre create hotspots (Exhibit 1), which
often merge to cover large areas exposing millions.
People have worked on cleaning up London’s air since the 1840s when smoke
from London’s lime kilns was first regulated. Power stations have been closed
Exhibit 1: Expected annual average concentration of toxic NO2 gas in Central
or cleaned up, coal burning banned, vehicle engines redesigned, millions of London in 2015. Yellow, red and brown areas are above UK and EU legal limits.
catalytic convertors and filters fitted to vehicle exhausts and novel regulations About 30% of NO2 is released from vehicle exhausts, hence the high levels around
like the congestion charge and LEZ implemented. As a consequence air quality roads. The remaining 70% from buildings, aircraft, industrial processes and diesel
trains contributes to a background miasma of air pollution. Map courtesy of the GLA.
has improved enormously, but despite the numerous actions already taken,
Central London still has air pollution levels that harm the health of commuters
The extent to which people are affected by air pollution is very strongly
and residents alike, whether compared with UK, EU or World Health
influenced by their proximity to the pollution source, the pollutant type, and the
Organisation standards [LAQN, 2012]. Pollution levels consistently breach UK
state of their own health [Pope, 2002]. The old and the young are particularly
and EU legal limits and medical evidence suggests that several hundred
vulnerable, as are those suffering from ill health. During moderate or high
Londoner’s die younger each year due to locally emitted air pollution [Miller,
pollution episodes, vulnerable individuals can try to cope with the pollution by
2010], similar to the number of those killed on London’s roads each year.
avoiding the most polluted areas when outdoors and ensuring they have a
supply of their medication, particularly people with asthma or COPD [COMEAP,
2011]. Over the long term, breathing polluted air for years affects everyone and
9 - 14 Cost Effective Actions To Cut Air Pollution In Central LondonPar Hill Research Ltd, Science, Environment & Policy Research
Exhibit 2: The
reduces lifespan through increased likelihood of developing cancer, heart Relative Risk of fine
Nature Of The Problem
PM particles
failure, stroke, asthma, COPD and other serious illnesses (Exhibit 2). Diesel
(PM2.5) shows how
exhaust is a known carcinogen and exposure should be reduced [WHO, 2012]. higher
concentrations of
Pollution levels fluctuate constantly in response to changes in pollution PM cause higher
sources, wind, heat induced overturning of air and the chemical reactions that levels of disease.
Also shown are the
pollutants undergo as they react with each other, with rain and with sun. In a
WHO, California, US
matter of minutes pollution can go from low levels to toxic levels [AQEG, 2004
Frameworks
EPA and proposed
& 2005] as winds drop, traffic builds up releasing exhaust fumes, the exhausts EU limits on PM2.5
concentrations.
and wheels blow previously settled PM dust back into the air and sunshine
Exhibit courtesy of
drives chemical reactions that convert NO2 into both toxic ozone gas and B. Brunekreef, U.
chemicals that create additional PM pollution. These fluctuations are monitored Utrecht.
at 48 sites across London on an hourly, daily and annual basis both to
understand the processes that drive the pollution and to monitor compliance [Cambridge, 2009]. Better home insulation would save both money, air
with UK and EU air pollution laws [LAQN, 2012]. The conditions that lead to pollution and lives. The increasing prevalence of extensive, poorly considered
moderate or high pollution episodes in London are well understood. Some are glazing in buildings means that workplaces and homes make increasing use of
largely beyond our control, for example during atmospheric inversions, when air conditioning in hot weather, driving emissions from power stations. And the
the air over London develops a structure that traps any pollution that is needs of developers to conform to carbon emissions targets using what they
released in the city, sometimes allowing it to build up for days at a time. Or perceive to be the simplest approach available has increased the use of wood
when we experience light easterly winds and they carry pollution to London and other biomass burning for heat. This emits huge amounts of smoke and
from the great urban and industrial centres of Europe, such as the Netherlands threatens to overturn 20 years of progress in air pollution reduction in London
and the Ruhrgebiet. [AEA, 2007].
Other conditions that cause moderate and high pollution episodes are directly To avoid the long term pollution exposure that leads to cancer, heart disease
under the control of Londoners and are a result of the choices we make, both and other major disorders, Londoners are faced with only two choices: to leave
individually, collectively and politically. Intense, dense traffic causes higher London for a cleaner place, or to act to reduce the pollution emissions that we
emissions of pollution during the rush hour when 200,000 of us take cars, generate, both individually and collectively. If we choose to act, we must
buses or taxis into the centre for work or taking our children to school [TfL, choose carefully, as every action has costs as well as benefits. We consider
2010a]. In principle, these emissions could be avoided through better spatial how to carefully choose between potential actions on the next page.
planning and traffic management or different choices of traffic mode. During
Appendices
cold weather, in our efforts to keep warm and healthy we tend run our heating
more. This too releases more pollution, but is exacerbated by the fact that
many of us live in poorly insulated dwellings with old and inefficient gas boilers
10 - 14 Cost Effective Actions To Cut Air Pollution In Central LondonPar Hill Research Ltd, Science, Environment & Policy Research
Strategic Approach To Assessing Actions co-benefits approach set out in DfT’s highly regarded Transport Analysis
Strategic Approach
Guidance (TAG) [DfT, 2005]. This expresses the overall benefits and costs of an
Delivering the actions needed to address air pollution often involves
action in terms of a monetary Benefits:Costs Ratio (BCR), derived from the Net
overcoming complex social, economic, political and sometimes emotional and
Present Value in 2012 of quantitative estimates of;
ideological hurdles. For example, although London’s Black Taxis are the source
of more than 50% of exhaust PM in Central London, their iconic design is • the cost reductions arising from the action, say from fuel savings;
widely cited as impeding renewal of the taxi fleet to cleaner vehicles, as it
restricts political options in opening the market to alternative designs. To • air quality benefits of the action as IGCB Damage Cost [Defa, 2009];
succeed in addressing such daunting challenges, dispassionate and clear
• the HMT Shadow Price of Carbon reduction from any carbon reductions;
evidence is required that looks at the whole cost of a potential action. The
general strategic approach required - and the approach taken here - must be • any other financial costs or benefits such as higher fares, income from
comprehensive, taking account of the costs and benefits to all those affected, PCNs, camera installation costs, increased cycling etc;
and considering whether an action can realistically be delivered given the
The HM Treasury Deflators were used as the discount factor. A qualitative
regulatory environment and the actions’ economic and social consequences,
and whether the action is worthwhile given the effort needed to deliver it versus assessments of noise impacts of the action was included, though some
aspects of TAG were beyond the scope, including impacts on historic buildings
the benefits it would bring. This is strategy the used in this work.
and biodiversity. Under TAG, a BCR greater than about 2 is considered
This work compared 94 potential actions that could be applied in Central suggestive of a cost effective action, so actions with BCR of around two or
London, using a holisitic, quantitative approach combining financial, more have been highlighted and divided into three major categories:
environmental, regulatory, civic and socio-economic factors. An initial long-list
of 94 potential actions was derived from interviews with more than 40 • large Impact Actions, that can cut emissions from a sector by 10%;
transport, sustainability, climate, planning, forestry, environment and air quality • episode Reduction Actions, that can cut emissions locally by 5%-10% in-
officials, NGOs and scientists in London, San Francisco, New South Wales and day during a high air pollution episode;
New York. Additional enquiries were made in Barcelona, Seville, Amsterdam,
Copenhagen and Sweden. A desk based review of over 400 official reports, • quick Win Actions, with a BCR >> 2, but a small impact.
peer reviewed publications and databases allowed 44 of these to be eliminated
The actions are described in either a detailed Framework or short Factsheet,
or amalgamated, giving a short-list of 50 actions. These 50 were discussed in
depending on their scale or benefits. Those not recommended are described
a round-table workshop with 10 experts on regulation of Central London’s air
last, and additional information on a Crossrail station is also included.
quality for their regulatory and civic feasibility and reduced to a final list of 27
actions to be studied in detail. In four cases work is ongoing elsewhere and
additional study would have been duplication. The remaining 23 were
examined in detail and included actions in the transport, buildings, business
operations and behaviours sectors. The methodology used was the holisitic
11 - 14 Cost Effective Actions To Cut Air Pollution In Central LondonPar Hill Research Ltd, Science, Environment & Policy Research
Recommended Actions testing the effects of roof exhausts, Euro IV bus engine reprogramming and
2667
DPFs on Euro III taxis should be implemented immediately.
£4M
BUSINESS ENGAGEMENT PROGRAMMES (BCR > 22, £4M savings), in
which large businesses with major centres in the area are engaged on a 1-2-1 The GLA proposal requiring NEW BUILDINGS TO BE AIR QUALITY 15
22 basis and programmes that reduce air pollution and costs are enacted. NEUTRAL is essential. This can be delivered cost-effectively by REQUIRING
CSH OR BREEAM LEVEL 4 in many cases, or the Passivhaus standards for
CAR CLUBS (BCR > 13, £8M revenues) should be expanded as quickly as 400
£8M more intensive developments. Ensuring old BOILERS ARE REPLACED BY
possible using clean cars. They reduce use of cars and replace dirtier cars with
ULTRA-LOW NOX MODELS INSTEAD OF CLASS 4 OR 5 will reduce
14 cleaner. They also generate net revenue for councils.
emissions by a further 40%-80%. Uptake of Warm Front, CERT, Green Deal
ECODRIVING TRAINING (BCR 6, >£7M savings) programme rolled out to all etc should be encouraged by councils. Wood fuels must be avoided.
£8M
taxi drivers will save them money, cut air pollution and improve road safety.
CYCLING (BCR > 2.5 and probably much higher) should be reclassified as the
6
ZERO EMISSION LAST MILE DELIVERIES (BCR 4) can be delivered primary mode of road transport in Central London for money saving, health
competitively by a number of companies in Central London, whether stationery and air pollution reasons. A staged approach can initially emphasise high
4 firms, taxis, couriers or supermarkets. A Central London list of service benefit, low cost actions such as cycle to work schemes, trials of low-cost
providers should be drawn up and their use recommended in public and cycle track designs and co-ordination of cycle promotion, training £209M
private procurement (such as in Business Engagement Programmes). campaigns and events across councils. Later improved and harmonised
signage and way-finding across the current several hundred km of 2494
IDLING ENFORCEMENT (BCR 4) should be applied experimentally to taxi Central cycle lanes would both advertise the infrastructure and improve
ranks with 200 taxis, such as Paddington Station. If good compliance is journey times and safety. Once low-cost designs are proven, the cycle lanes
1.3 185
achieved it should be rolled out to smaller ranks. It is unlikely to be cost should be upgraded to tracks everywhere that roads are wide enough.
4 effective for buses, LGVs or HGVs, except for bus stands of 7 or more. Finally, accelerating expansion of the Cycle Hire scheme is likely to
substantially add to cycling numbers.
CAMPAIGN DAYS (BCR 1.7) to reduce in-day car and taxi use through public
advertising should be planned for next Spring. Spraying CMA dust
2
suppressant (BCR 1.7) is also effective in the worst polluted streets.
1.7
These seven won’t substantially reduce air pollution. To do this, the following
large impact measures are recommended, which can also save £248M.pa.
Symbols illustrating the action’s key advantages
Actions
Recommended
VERTICAL ROOF EXHAUSTS ON BUSES, A EURO V ONLY CENTRAL High Benefits:Costs Ratio, BCR £4M Cost savings or revenue
22
BUSES ZONE, and RETROFIT OF ALL EURO III TAXIS WITH DPFs, figure for 2012 shown generation, Millions of 2012 £
should be implemented and could be enforced through a sectorally agreed 1.3 Strong PM Reduction, 400 Strong NOx Reduction,
LEZ in the Centre, with the threat of an enforced TRO based LEZ. Pilot projects Tonnes per annum Shown in tonnes per annum
Councils Leading by example
12 - 14 Cost Effective Actions To Cut Air Pollution In Central LondonPar Hill Research Ltd, Science, Environment & Policy Research
Table of Cost Effective Actions
All figures given are approximate, based on the evidence available. For full
details of each action see the Full Guidance document.
Measure Impact Ratio of total Benefits NOx reduction PM10 reduction CO2 reduction Noise
timescale from Benefits / total (NPV in 2012) tpa tpa tpa improvement
policy decision costs
Replacement of old boilers with Years-Decades Infinite Not calculated 566.00 8.00 Not estimated 0
Ultra-low NOx devices (as zero cost)
Business engagement (ongoing for 6 Months 22.11 £4,630,096 0.07 0.01 34.92 +1
years)
Car Clubs Expansion Programme Months 13.58 £7,558,993 28.53 1.40 26,915.65 +1
Cycle to Work Schemes Expansion Months 6.22 £4,567,538 3.54 0.33 2,171.49 +1
Ecodriving Training for Taxi Drivers Months 5.75 £7,683,700 4.14 0.36 2,023.22 +1
ZEV Last Mile deliveries Weeks-Months 5.05 £4,046 0.02 0.00 20.46 +3
Taxi Rank Idling Wardens Months-Years 4.12 £546,572 0.96 0.35 1,490.54 0
Cycle infrastructure & Promotion Years 2.49 £209,912,924 249.48 18.59 150,685.92 +3
using low cost cycle tracks
Cost Effective Actions
Table of
Vertical Exhausts at roof level on Months 2.46 £24,015,078 2,667.15 21.15 - 0
buses
Euro V requirement for Central Months 2.41 £2,123,339 204.71 1.34 - 0
London buses & Euro IV engine
reprogramming
Fitting DPFs on Taxis Months-Years 2.01 £27,916,732 0.00 15.28 - 0
Campaign Days Days 2 £2,500,000 15.00 2.40 20,000.00 +1
Totals 6.2 Average £ 291,459,018 3,740 t.pa NOx 69 t.pa PM 203,342 t.pa CO2 +1=some,
(Average for BCR) BCR +2=significant,
+3=substantial
13 - 14 Cost Effective Actions To Cut Air Pollution In Central LondonPar Hill Research Ltd, Science, Environment & Policy Research 14 - 14 Cost Effective Actions To Cut Air Pollution In Central London
Par Hill Research Ltd, Science, Environment & Policy Research
LARGE IMPACT
ACTIONS
LARGE IMPACT ACTIONS
LEZs: bus roof exhausts, bus reprogramming & taxi DPFs
CYCLING: pollution & fiscal benefits, cheap ways to increase it
BUILDINGS: energy efficiency, renewables & building standards
Large Impact Measures can reduce air pollution by 10% or more from a
given source. The following frameworks detail three sets of Large Impact
measures in Central London, providing expanded and relevant evidence for
air quality specialists, outlining the required regulatory frameworks and include
some suggestions for delivery.
15 - 14 Cost Effective Actions To Cut Air Pollution In Central LondonPar Hill Research Ltd, Science, Environment & Policy Research
LEZs
Summary of LEZ Options Examined
Three Viable Low Emission
Central LEZ LEZ requiring LEZ requiring Central LEZ
requiring bus exhausts bus exhausts Euro IV Bus
Zone Options Scenario
DPFs on Euro
3 Taxis
on the roof
(50% impact)
on the roof
(90% impact)
via engine
reprogram
NOx baseline 3,663t (all 3,663t (all 1164t (Central
(not affected)
emissions, 2015 London TfL) London TfL) London only)
Although London already has the World’s largest LEZ setup by the GLA,
PM10 baseline
London boroughs have the powers to apply a Central LEZ(s) on their own emissions, 2015
41.25t 23t 23t 9.8t
highways. Since an additional LEZ for HGVs would be duplication, and LGV
NOx reduction,
and car LEZs are not thought to be cost effective in Central London [TfL, pa
- 1,481t* 2,667t* 204t
2011b], three measures were considered that could be applied using LEZ
PM10
powers to substantially reduce pollution from taxis and buses in Central reduction, pa
18t 11.75t* 21t* 1.3t
London. All three were found to have the potential to reduce toxic pollution or
PV of NOx
its impacts by 20%-90% from taxis or buses, with Benefits to Costs Ratios of Damage Cost
- £9M £16M £1.2M
greater than 2 in all cases, but no fuel reduction, CO2 or noise benefits.
PV of PM
£17M £13M £23M £1.8M
Damage Cost
The approach tested for taxis requires Euro 3 taxis to have a DPF fitted to be
allowed to operate in Central London. This is found to reduce PM emissions Cost Effective?
Yes (2.0) No (1.86) Yes (2.46) Yes (2.41)
(BCR)
from taxis by 18t in Central London, or 43%. Two approaches were considered
for buses: high level exhausts and Euro IV engine reprogramming. High level
exhausts (as applied routinely in the US and Australia) were found to have the
LEZ Exhibit 1: Summary costs & benefits of three LEZ options in Central
potential to reduce the impact of PM and NOx emissions by 50%-90%. Diesel London. Euro 3 DPF Taxi Retrofit LEZ; TfL Bus High Level Exhausts, giving 50%
engine reprogramming, as executed in Bristol for buses and Manchester for impact reduction; TfL Bus High Level Exhausts, giving 90% impact reduction; TfL Bus
fire tenders, was estimated to reduce emissions of NOx and PM by about Euro IV-V reprogramming; The taxi DPF and bus vertical exhaust measures are
assumed to have impacts across London, while the Euro IV-V bus reprogramming is
13%. Of these three, the taxis DPF retrofit and high exhausts on buses deliver expected only to affect buses in Central London.
the most substantial improvements for the effort involved in deliver the
measures. Introduction to LEZs
The regulations and procedures to establish LEZs are described in detail, along Low Emission Zones allow certain classes of vehicle to be banned or restricted
with the potential pitfalls and opportunities for leverage. The simplest approach from travelling or parking in a certain geographic area so that air pollution
emissions are reduced. The LEZ can apply to any clearly identifiable and
uses Sectoral Agreements reinforced by operating contracts. Another creates
a legally enforceable LEZ through a Traffic Regulation Order (TRO). reasonable categorisation, e.g. engine size, Euro emissions category, CO2
16 - 14 Cost Effective Actions To Cut Air Pollution In Central LondonPar Hill Research Ltd, Science, Environment & Policy Research
emissions, vehicle age, class or weight, fuel type etc, or a combination of The value of the 30p surcharge to the taxi drivers doing 13 fares per day (as
Taxi DPFs & Vertical Bus Exhausts
LEZs
these. This allows considerable flexibility in targeting the LEZ at certain indicated by CCZ unique vehicle counts) for five years would more than offset
emissions or sources. Experience in the UK is that LEZs can take a long time the cost of the DPF. The estimated value of the air quality improvements over
to establish. London’s LEZ required almost a decade of planning, while the life of the LEZ would be £27M, using the Damage Costs approach. This
Oxfords required four years. Because of the LEZ already in force in London, would be as a result of a reduction in PM emissions in Central London of 9
the options for councils to apply new LEZs are limited to private cars, LGVs, tonnes per year and in Outer London of 10 tonnes per year, on average.
taxis, buses and coaches. Of these sectors, LEZs for private cars and LGVs Agreement with TfL on the 30p surcharge would be required.
have already been shown by TfL to be non cost-effective. This leaves councils
Overall, the approach is found to be cost-effective, with a Benefits-to-Costs
with the options of LEZ aimed at taxis and buses. In developing the potential
Ratio of 2.0 equal to the TAG recommended approval threshold of 2.0.
technical requirements for such LEZs, lessons were drawn from experiences in
Continental Europe where DPFs have been successfully applied for LEZs, from
High level or vertical exhausts for Buses
the USA and Australia where high levels exhausts are routinely required, and
Buoyant (i.e. hot) emissions from a high
from Bristol and Manchester, where diesel engine reprogramming has been
used to reduce pollution. exhaust outlet will result in ground level
concentrations 65%-95% times lower
Euro 4 DPF Requirement for Central London Taxis than those from a low level outlet [CERC,
Commercially available Diesel Particle Filter (DPF) retrofit solutions exist to bring 2005; AustRoads, 1993; World Bank,
the 50% of licensed London hackney cabs that are Euro 3 standard compliant 1996], indeed it is on this basis that high
up to and beyond the Euro 4 particulate standard (though NOx emissions are level stacks are required for stationary
unaffected). An LEZ was modelling in which Euro 3 taxis are required to be sources. This effect is so demonstrable
fitted with suitable DPF equipment to be allowed to operate in Central London. that it is a pre-requisite for bus
If all the 10,500 Euro 3 taxis choose to comply, the equipment can be
procurement in many US and Australian
purchased for £1700 each (Gerd van Aaken, HJS UK, personal
states (Exhibit 2), and in 1987 the city of
communication) and installed for an additional £800. These costs are offset for
Santiago in Chile applied a mass retro-fit LEZ Exhibit 2: HIgh Level Exhaust
drivers through a 30p per fare emissions surcharge for the taxis so modified. It on a single decker bus in
p ro g r a m m e t o a l l i t s b u s e s w i t h Queensland, Australia.
is assumed that all the Central London Local Authorities collaborate to share
the studies and costs required to setup the LEZ and that these amount to considerable success in reducing air
£0.5M in 2012, which is defrayed by a £40 per year annual certification charge pollutant concentrations [World Bank, 1996]. UK HGVs often have high level
to each of the 10,500 vehicles to whom the LEZ applies. The LEZ is assumed exhausts as this reduces both ground concentrations and resuspension of
to operate from 1/1/2013-31/12/2017. road and works dust, and conversion of HGVs from low to high level exhausts
is routine and cheap. But high level exhausts are found on very few buses in
the UK and conversion of low to high is unheard of. Anecdotal evidence
17 - 14 Cost Effective Actions To Cut Air Pollution In Central LondonPar Hill Research Ltd, Science, Environment & Policy Research
suggests this may be due to the highly visible nature of exhaust emitted would lie between the two, this suggests that the measure may be cost
Vertical Bus Exhausts & Engine Reprogramming
LEZs
vertically from buses which is repugnant to bus and coach OEMs (J. Norris, effective - the TAG recommended BCR threshold is 2.0.
personal communication). A study for Defra into the impact of vehicle exhaust
The results suggest that if the basic physics supporting the findings in CERC’s
location on dispersion (CERC, 2005) suggests ground level concentrations study are not undermined by other evidence, high level exhaust retrofit is likely
close to the vehicle is of the order of 10-20 times lower from high level exhaust to be a cost effective means of reducing the impact of local bus air pollution. It
than low, and the maximum concentrations in the far field are at 20m range is recommended that a pilot study is conducted along a well controlled and
and are half the maximum from low level exhausts. The CERC report suitably instrumented bus corridor to establish the veracity of CERCs models.
recommended increased use of high exhausts. CERC’s study compared HGV outlets at low (0.3m) and high (3.5) levels on
HGVs. Roof level exhausts at 4.4m on double decker buses can be expected
To study the potential impact of high exhausts in Central London using an LEZ, to reduce ground level pollutant concentrations both in the near field and
an LEZ requiring high exhausts on TfL buses was modelled. The approach downstream even further. Subsequent to a validation study, LEZs requiring
could equally be required of LGVs, HGVs or coaches, but these are excluded high level exhausts for HGVs and LGVs should also be examined.
for the reasons previously outlined. As high exhaust retrofit is not a standard
procedure in the UK and approaches are likely to require novel devices, such Euro IV-V reprogramming requirement for TfL buses
as caged downpipes, costs per vehicle have been estimated by scaling up the The MAQS sets out a plan for replacement of parts of London’s bus fleet so
cost of an HGV high exhaust retrofit (typically £500) to £2,000 per unit. For the
that between 2011 and 2015, Euro IV buses will go from 19% of the fleet to
purposes of the scenario, the conversion is applied to all 8,000 TfL buses. The
21%, Euro V buses from 15% to 34% of the fleet, Euro VI & V-Hybrid buses will
air pollution impact is determined as though the effect of the changed
make up 2%, Euro III buses will have DPFs and NOx scrubbers fitted, and Euro
dispersion characteristics was a change in the annual emissions rate, and two
II buses will be phased out. Cases in Bristol and Manchester show that in
scenarios were considered: a reduction of 50% and of 90% in effective many cases it is simple and inexpensive to reprogram the engine computers of
emissions. The 50% reduction is representative of the down-stream impacts
Euro IV diesel engines to achieve the Euro V standard. In Manchester,
estimated by CERC, while 90% (or better) is representative of the kerbside
reprogramming of 39 fire appliance engines cost £34,000 and was available
impacts. Real world impacts would lie somewhere between the two, probably
from OEM representatives. The Manchester case illustrates the method may
closer to the range of 67%-87% cited by the World Bank (1996).
be applied to other vehicles than buses, including some coaches, LGVs and
The estimated impacts (Exhibit 1) are found to be equivalent to a reduction in HGVs, but for this scenario the bus model is used.
emissions of 1,500t per annum of NOx and 12t pa of PM for the 50% case,
This scenario examines an LEZ taking advantage of this upgrade mechanism.
and 2,700 NOx and 21t PM per annum for the 90% case. The subsequent
The proposed mechanism is a Sectoral Agreement with TfL and bus operators,
reduction in socio-economic Damage Cost is £22M over 6 years for the 50%
as a result of which they would apply a Euro IV to Euro V upgrade to all
case, and £39M for the 90% case. As the cost of implementing the measure is
suitable buses and operate only these within the Central London area. The
assumed to be around £16M, this leads to a Benefit-to-Costs ratio of just cost is estimated to be £1M for the 1,200 or so affected buses, based on the
under 2 for the 50% case, and 2.5 for the 90% case. As the actual outcomes
costs of the Manchester example. The councils’ would reserve the option of
18 - 14 Cost Effective Actions To Cut Air Pollution In Central LondonPar Hill Research Ltd, Science, Environment & Policy Research
imposing an LEZ through a TRO on council’s Highways in the event of coaches inside the CCZ) makes approximately 11 vehicle movements inside
Bus Engine Reprogramming
LEZs
difficulties achieving a sectoral agreement. To account for this possibility, an the zone. While it is not possible to disaggregate non-TfL coach movements
LEZ setup cost of £0.5M to the councils is assumed, offset by an annual £80 from the total, it is possible to estimate their relative contributions. UVCs from
certification charge. The effect on air pollutant emissions in Central London is the LEZ [TfL, 2008] show that non-TfL buses and coaches make up around
estimated to be a reduction of 204 tonnes NOx and 1.6 tonnes PM10 per 4,000 of the 12,000 buses in London overall. If non-TfL coaches are assumed
annum, and reduced socio-economic Damage Costs of £3M over six years. to make two round trips per day and the 2:1 TfL:non-TfL ratio for all London
Allowing for a possible LEZ setup cost of £0.5M, this gives a Benefits:Cost holds in Central London, then TfL buses must make up about 87% of all
ratio of 2.4, above the TAG cost effectiveness threshold of 2.0. emissions in Central London. The 2008 LAEI bus emissions data (projected
forward based on the MAQS) have been corrected for this factor. The
This scenario overlooks two second-order costs and benefits. The first is any contribution of frequent inter-city buses within the home counties such as to
efforts currently made by TfL to direct lower emission buses to Central London.
Oxford or Luton have not been accounted for as no data is available on this.
The MAQS indicates that 42% of TfL buses are already Euro IV or V compliant
in 2012, or some 3,600 buses. The number of buses estimated to be Estimate of errors arising from un-modelled activity changes
operating in Central London is around 4,000 (see Model of Unique Vehicles), Annual emissions changes by sector were based on fleet engine class mix
which suggests that a substantial number of Euro III and older buses are data from the MAQS and TRL published emissions factors. This projected
operating in the area in 2012 and their removal and the upgrade of Euro IV forwards the emissions assuming a steady size of fleet, making it vulnerable to
buses to Euro V would be worthwhile. The MAQS indicated that around 4,000 un-modelled changes in fleet activity or emissions factors. This study’s
buses should be Euro IV or better by 2013, so there should be sufficient buses projections were compared with the MAQS projections, this showed that the
to operate the Central London routes. Second, the scenario does not account methodology used here underestimates NOx projections by 1%/year and over-
for the benefit of the reduction in Damage Cost arising from moving dirtier estimates PM projections by 5%/year.
buses from the high populated Central London to the less densely populated
areas of Outer London.
A note on the bus emissions data used in Scenarios B & C
The scenario uses a simplified model of Central London bus emissions based
on the 2008 LAEI projections. This includes a contribution from non-TfL mini-
buses and coaches. Unique vehicle counts (UVCs) from CCZ cameras (C.
Buckingham, TfL, personal communication) show that Mini-buses under 5t
(M2 class) make-up 14% of buses inside the CCZ area, but only 4.4% of
vehicle movements. M2 emissions per km are typically 10% of those of an M3
class bus weighing around 18t [TRL, 2009], so their total contribution to the
emissions would be less than 1% of the total bus emissions. CCZ UVCs also
show that each M3 class bus (which includes all TfL and non-TfL buses and
19 - 14 Cost Effective Actions To Cut Air Pollution In Central LondonPar Hill Research Ltd, Science, Environment & Policy Research
systems. Charges may be made by the Authority as part of the registration or
The Relevant Regulations
LEZs
Establishing an LEZ - the relevant regulations
certification process so costs can be defrayed. The Authority is also
The remainder of this chapter is given over to the processes and regulations
responsible for enforcement and associated costs, and must carefully consider
required to establish an LEZ. LEZs in London can be setup using a number of
the costs of this as part of the business case in appraising LEZ choices. The
regulatory and non-regulatory approaches. The current London LEZ was
boundary of the LEZ must be clearly demarcated by signage at all entry points.
established using powers in the Greater London Authority Act to create a traffic
Guidance indicates Sign 619 Motor Vehicles Prohibited with listed exemptions
charging scheme. But this approach would require use of the GLA process
may be adequate [Defra, 2009a].
and councils would not be able to act independently. The Oxford bus LEZ was
established through a Condition by the Transport Commissioner on the bus The design of the LEZ should be considered in the framework of DfT Transport
operators. Again, this route is not directly available to London Local Authorities. Analysis Guidance (TAG), based on the now deprecated New Approach To
Section 106 LEZs can also no longer be applied. Appraisal for transport projects. TAG is a best practice framework for all
English transport projects, and has been adopted not only in other UK nations,
For London Local Authorities, that leaves two approaches: A Traffic Regulation
but also by international institutions. Preparation of air quality related transport
Order (TRO) or a sectorally agreed LEZ. A TRO can be used to create a
projects in conformance to TAG may accelerate their uptake. The effects of the
penalty charge for forbidden vehicles or to establish differential parking charges
LEZ on transport operators and users should be considered against the TAG
by the chosen category, under powers from the Road Traffic Regulation Act
transport objectives:
(1984), the Road Traffic Act (1991) and the Traffic Management Act (2004).
Establishing a TRO requires significant administration, planning and technical 1. reducing transport’s environmental impact. In London the most relevant
assessment, described in more detail later. An LEZ established by Sectoral impacts are on atmospheric pollution, noise, wildlife and historic buildings;
Agreement also requires appraisal and consultation, but is less onerous than
2. improving safety of people and property;
and has the potential to be implemented more quickly through negotiation.
Negotiation of Sectoral Agreements can be assisted through application of a 3. improving the economic efficiency of transport, both for consumers,
contractual condition or through consideration of proceedings to setup a TRO business users, transport providers and the wider economy;
based LEZ, which could be more onerous for the affected sectors. 4. improving people’s ability to get to different locations by different modes;
and
As outlined earlier, any clearly identifiable (sub)category of vehicle can be
restricted by an LEZ, such as engine size, Euro class, CO2 emissions, vehicle 5. improving transport integration.
age, class or weight, fuel type etc. The responsibility for managing the How these objectives can be appraised is outlined later. For more detailed
identification scheme falls to the Authority unless it is a pre-existing scheme,
information on TAG see the DfT online guide at www.dft.gov.uk/webtag.
such as DVLA, VCA or VOSA schemes, or the Reduced Pollution Certificate
scheme established by TfL for London Taxis. The identification scheme could
involve paper documents, stickers or badges to facilitate manual enforcement,
or number plate registration for automatic number plate recognition (ANPR)
20 - 14 Cost Effective Actions To Cut Air Pollution In Central LondonPar Hill Research Ltd, Science, Environment & Policy Research
Three Examples
LEZs
Three examples of LEZs in practice
London Berlin Oxford
• Cross part agreement, including during a • Cross party agreement. • Early cross party and cross authority
change of Mayoralty. • Phased implementation. agreement.
• Staged implementation. • Funding for upgrade and retrofit. • Buses could be regulated by the LTA
• LGV bulk purchase scheme arranged. through a Road Traffic Condition. RTC
• Substantial work done on stationary
used to setup the LEZ.
• Grant of £10M for 100 new buses from sources, improving access using low or no
DfT Green Bus Fund. emissions modes and traffic smoothing • Grant of £3.5M for 43 new buses from DfT
before the LEZ was considered. Green Bus Fund.
• Those affected most able to afford
implementation costs. • Now described by Berlin Senate as the • Over 60% of city centre NOx emissions
most effective measure applied. due to buses.
• Early action on the directly controlled
sources - buses had particle traps fitted. • Hotspot & urban background LEZ • Hotspot LEZ
• Additional action on regulated sources - • Area of 88km2 • Area of 6km2
black taxis required to have Euro 4 • LGVs & Cars controlled since 1.1.10: • Affects 111 buses running through some
compliance and age limits. Mini-cabs also city centre roads - buses account for 64%
required to meet Euro 4 standard. • Diesel vehicles must be Euro 4 (post 2006)
of local NOx emissions.
or Euro 3 + filter; Petrol vehicles must be
• LEZ initially applied to HGVs and coaches, Euro 1 (i.e. post-1993).
now also to LGVs.
21 - 14 Cost Effective Actions To Cut Air Pollution In Central LondonPar Hill Research Ltd, Science, Environment & Policy Research
The decision to consider an LEZ must be taken in the wider context of other
Strategic Considerations
LEZs
Strategic Considerations in LEZ Design
relevant spatial, economic and transport strategies. For example, can the LEZ
LEZs can be used to address an air quality problem where fleet turnover and
be used to increase local footfall to businesses by reducing congestion and
other cheaper measures are insufficient to achieve the air quality objectives
improving conditions for pedestrians and cyclists. Can the LEZ be used to
and reduce or minimise the socio-economic cost of air pollution.
reinforce actions to reduce health inequalities? The LEZ must be considered
Design of an LEZ should aim to meet one over-arching strategic goal: holistically within context of the overall Authority strategy.
maximising the reduction in air pollutant concentrations for the
minimum economic, financial and civic cost, so air quality and other Technical issues in LEZ Design
strategic objectives are achieved and the health of residents benefits. In technical terms, the key considerations are the boundaries of the LEZ, the
vehicles affected and the emissions change required and the start date of the
Essential to this question is whether an LEZ is the best way to achieve the LEZ. Judicious combination of these factors can be used to focus on delivering
required outcome, and whether it provides value for money. Subsidiary reductions in urban background, sub-regional or local hotspot concentrations.
questions to address include:
Examples of each include the London, Berlin and Oxford LEZs respectively.
While the benefits of the London LEZ are well know, evidence suggests that
• Ensuring benefits to local stakeholders are greater than overall costs. In this
regard stakeholders include transport operators, local businesses, the sub-regional and hotspot LEZ in Berlin and and the local LEZ in Oxford
residents, the local NHS, social care providers, and those vulnerable to air have been very effective. In Berlin, cars and Light Goods Vehicles have been
pollution and their representatives such as Asthma UK and the British Lung targeted and measurements indicate that in 2010 10-15 fewer PM exceedence
Foundation. days occurred inside the 88km2 of the LEZ than in the 800km2 of Berlin
outside, a major improvement on the situation before the LEZ implementation
• Ensuring the actions taken are financially and politically viable for the [Rauterberg, 2011]. The Oxford LEZ targets buses inside 6km2 of Central
Authority and stakeholders affected. Relevant factors include setup, Oxford, and has led to a major renewal of the Oxford bus fleet through
operation and enforcement costs, retro-fit and vehicle upgrade costs, also judicious application to the Green Bus Fund.
political will, early cross party engagement and active public engagement.
Engaging Members, other Authorities and the public should begin early in In developing LEZ technical options for appraisal, the elements to consider are:
development.
• Source apportionment of emissions;
• Finally, the design of the LEZ should consider the technical objectives, • Locations where concentration reductions are required;
allowing for the UK’s NO2 and PM10 objectives, the CAFÉ requirement to
minimise PM2.5 concentrations, potential future evolution of the PM and • Number of vehicles needing upgrade to deliver the benefits;
NO2 objectives, and the potential for unexpected outcomes from new • Level of regulatory control of those vehicles - can they be controlled
technologies or unfavourable weather conditions. through procurement or PSV licenses, or is a TRO required;
• Cost and feasibility to operators of upgrading their vehicles;
22 - 14 Cost Effective Actions To Cut Air Pollution In Central LondonPar Hill Research Ltd, Science, Environment & Policy Research
• Method and cost of enforcement and the resulting business case;
Stages of LEZ Development
LEZs
Stage of Stages of LEZ Development
• Year of implementation. Process Using TRO
Development Process
Defra’s IGCB analysis indicates that since 2010 the most cost-effective
Screening Assessment (4-6m) minimum standards for UK LEZs are Euro 5 for LDVs and Euro IV for HDVs,
Technical appraisal: boundaries, vehicles both in toxic pollutant and fuel efficiency terms [Defra, 2009a].
affected, emissions standards, implementation
plans, reporting process for Cabinet approval, Outline of LEZ development process
alignment with LIP.
The process of LEZ development is dictated by the TRO process laid out in the
Intermediate & Detailed Assessments (6-12m) RTRA, RTA and TMA. The process (illustrated overlead) should follow the best
Including full economic CBA, updating of the
detailed inventory and detailed dispersion practice laid out in TAG, whose Appraisal Framework comprises four elements:
modelling. Signage design. Possible SEA.
1. An Appraisal Summary Table, showing how National objectives are
Consultation, Revision, Preparation (6-12m) achieved, the overall cost-benefit analysis and an assessment of the value
Publication of scheme for public and police, LTA, for money ;
DfT, businesses, bus co. etc. Response to
objections, revised scheme, legal responses 2. An assessment of how regional and local objectives are achieved by the
where challenged. LEZ and the actions and projects it supports and is supported by;
3. An analysis of how effectively the air quality (and potentially other
Setup & Installation (6-12m)
Either install cameras etc, or setup scheme to problems) will be solved by the LEZ;
manage and enforce discs. Install signage and Start of LEZ
4. Supporting analyses which consider issues of distribution and equity,
street markings, communicate start date.
affordability and financial sustainability, and practicality and public
Enforce, Monitor, Report (permanent) acceptance of the LEZ.
Monitor effects on traffic & AQ. Enhance AQ
monitoring to suit. Report on scheme progress The essential tools required for this are cost-benefit analysis, air pollution and
and effectiveness. traffic modelling, Geographic Information Systems and potentially EIAs or
SEAs, though the latter are unlikely for a small LEZ. The process begins with
Communications (ongoing)
Cross-party and cross-boundary engagement. development and appraisal of a series of options for the LEZ. In the London
Information for stakeholders and the public on case, Central LEZs are limited to measures not already delivered by the
the benefits of the scheme and it’s impacts. Greater London LEZ. If analysis of these options suggests an LEZ is an
Involvement of operators and affected groups.
appropriate and effective measure to take in Central London context (as some
Projects to support LEZ (ongoing) of our Scenarios indicate), the next step should be engagement with senior
Implementation of LEZ
Idling reduction, Bus routing, Smart driving, filter Design of LEZ support projects
Authority executives and elected Members to consider whether the measure is
& upgrade grants and finance, cycle support projects
likely to achieve political support. LEZs can be controversial and cross-party
infrastructure, bus corridors, public engagement.
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